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The proposed off-site purchase and preservation of a minimum of 12.5 acres of prime mature riparian forest would not serve to replace the habitat recently lost due to project actions. It will in fact be necessary to restore a much larger area D159 and take an extended period of time to accomplish this mitigation. No further project activities should be allowed to proceed until this mitigation is complete. The only appropriate compensation for the significant impacts that have already occurred would be to provide permanent conservation protection for the remaining area. This would also require the current development proposal to be dropped. The conclusions that California tiger salamanders or giant garter snakes are not present at the project site is difficult to evaluate based on the information D160 provided. These species are both secretive and sensitive to the prolonged drought conditions that have occurred. It would be necessary to extend and expand the studies performed in order to conclude whether or not either of these "herps" are in fact present. Similarly, the effort made to determine whether three protected invertebrate D161 species were present on the site was inadequate. Further investigations need to be made for each of these species. The fact that there is suitable habitat for each I species is adequate to require mitigation alone. The loss and disruption of nesting and foraging habitat for the Swainson's hawk would not be adequately mitigated by any or all of the measures identified. No D162 further development activities should take place and there should be a full mitigation and enhancement plan developed and implemented to compensate for those impacts that have already have occurred. The full success of this type of plan will require a longterm quantitative monitoring program to be conducted by a qualified biologist. I The proposed mitigation measures to offset the loss of Swainson's hawk foraging habitat are unproven. There is inadequate information to conclude that the D163 foraging behavior of Swainson's hawks would not be impacted by the project in Ispite of the proposed mitigation. The proposed "restoration" of Tracy Lakes would be offset by the increased human impacts that would occur as a result of this development. While the D164 restoration activities are desirable and should be developed further, there will certainly be greatly increased human impacts in spite of the proposed restrictions. I The proposed herbicide use regulations and development restrictions would in fact only be advisory. Impacts from these very activities will still occur, even if it D165 is at a somewhat slower rate than for some other developments. The close proximity of this development and the human activities that would result would I in fact have cumulative adverse impacts to the Brovelli Woods ecosystem. The VI-144